For a gain or loss to be within the scope of tax on chargeable gains, there must be a chargeable disposal of a chargeable asset by a chargeable person. See C1.104, C1.103 and C1.102 respectively.
Individuals, trustees and personal representatives are subject to capital gains tax on chargeable gains. Companies are subject to corporation tax on chargeable gains. See C1.102.
This article discusses the history of so-called Mansworth v Jelley1 losses (named after the case of the same name) and whether these carried forward losses can be used against capital gains. For the computation of chargeable gains and losses, see C1.105.
For an overview of allowable capital losses, including how relief is given for allowable losses, see C1.106.
Mansworth v Jelley losses for capital gains tax
Some taxpayers may have so-called Mansworth v Jelley capital losses arising on the disposal of shares acquired under an unapproved share option scheme where the options were exercised before 10 April 2003. These losses arose due to the then Inland Revenue's initial interpretation of the Court
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